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Sorry for just now seeing this... Section 13.8 of the NFA Handbook... It says that if you are an FFL/SOT you do not have to file one and obtain approval. "A person, other than and FFL/SOT, may not lawfully transport... ... without approval of ATF... 27 CFR 478.11."

With that said... I know a lot of dealer that get one approved anyway because not everyone knows the rules...